to FINPOLCONSULT, the financial sector development specialist and think tank.

My company offers specialized economic, market and legal-regulatory analysis and advice at the intersection of capital markets, mortgage markets and housing markets. In these areas, my work experience dates back to the early 1990s and I have been one of the pioneers of the profession.

During the Global Financial Crisis and the subsequent Euro crisis general financial sector development, banking regulation, sovereign and subsovereign finance became new and promising business lines. Since 2008 I have been a key independent voice in Germany and Europe on policy design in these areas.

My broader goal is to support the global knowledge base in the financial sector, help to develop more efficient and competitive businesses as well as transparent, stabiity-oriented and socially responsible public policies in this area.

If any of the links do not work and you are interested in the material, please e-mail me under aduebel@finpolconsult.de

October 2016: quick comment on the volatile and weakening credit standards in German mortgage finance. One of the almost incomprehensible features of our market is that banks do not fix the maturity of the mortgage in advance. Rather the borrower pays initial interest plus a fixed initial amortization rate. This gives a maturity - currently e.g. with 2% interest and 2% amortization at 36 years - but it changes whenever interest rates change.

I
continue to do extensive private consulting work with generally
unpublished results, inter alia currently developing a housing finance
institution in a Central Asian country for a European development
agency.

Publication of our six
country Middle Eastern housing finance study is delayed, anticipated
for September. A French colleague, Olivier Hassler, and I analyzed the sector in Lebanon, Jordan, Palestine, Egypt, Tunisia and Morocco. The paper is with the editor.

Additionally I have finished a paper on European mortgage debt restructuring reviewing the Hungarian, Irish and Spanish cases that is currently under review and being published shortly.

The German Ministry of Justice has appointed me as an independent to a working group to evaluate potential Germany law changes regarding the consumer's right of early repayment of mortgage loans and prepayment indemnity formulation in Germany. See my 2014 internationally comparative study (in German). The EU Mortgage Credit Directive had left this field almost unregulated, see my November 2015 Korea PPT below.

July 2016: several comments and interviews published recently in Deutsche Wirtschaftsnachrichten on European banking sector issues (in German):

- Interview on
the inflationary use of bad banks in Europe as bank recovery tool, most recently
encouraged by the ECB in the context of concerns about Italian banks' high levels of non-performing assets. Bad banks
are the result of an asset swap at predetermined prices of dubious against good
assets. Investors in dubious assets during the European banking crisis have
been either government (Germany, Ireland) or highly subsidized private
investors (Spain). Yet, dubious asset prices are near impossible to determine in
crisis situations. The approach has therefore often led to redistributions of
losses from existing bank equity and debt owners to government. The EU
Commission reacted in 2013 by imposing tight State Aid rules, demanding the bail-in
at least of junior debt investors, which also apply to the bad bank instrument.

Italy is
currently circumventing those - useful - rules by creating a nominally majority private investor
(Atlante vehicle) through regulatory arbitrage favoring their sub-investors, Italian
banks and institutions. The goal is to avoid bail-in esp. in Banca Monte dei
Paschi di Siena (BMPS), a bank that sold large amounts of subordinated debt to
retail investors.

Clearly
the better approach, esp. for deeply insolvent banks like BMPS, would be the
Good bank approach where dubious assets are left with historic equity and
subordinated debt to be unwound while deposits and senior bonds are sold
together with good assets. For good assets even in crisis there will be a
reasonably competitive bidding process, as the experiences of the US FDIC with
hundreds of such resolutions annually during the crisis show, and no need for additional tricks that will undermine both investor and taxpayer confidence.

- Comment on the Slovenian case, in which Swedish advisors during 2012 created a bad bank that served to rescue large amounts of subordinated debt in Novo Ljubljanska Banka (NLB) and other Slovenian banks, e.g. through liability management exercises. I put a slide on NLB in a 2013 presentation (p.9) in Cyprus that highlights the disappearance of bail-inable liabilities. The losses arising from the failure to bail-in even subordinated debt had to be borne by Slovenian taxpayers.

- Interview on current Italian banking sector issues and the Italian governments' hostility against bail-in measures. As in Spain during 2007-2012, Italy's delay in restructuring its banks since 2010 put retail investors in line of a potential bail-in while permitting professional bond investors an exit without losses. Retail investors were attracted through favorable tax treatments of bonds compared to deposits, and de-facto served as a lender of last resort for Italian banks in senior unsecured and subordinated bonds during the attack on the system in the fall of 2011.

- Comment on the European deposit insurance debate, which ignores that the bailout interventions of the ECB left
foreign investors off the hook for sharing losses of bank assets and -
because ECB is usually better collateralized or even de-facto super
senior (Cyprus) - thus maximized the potential losses for the local deposit base.
The result in Cyprus, as fmr. Bank of Cyprus CEO Evdokimos Xenophontes
has shown, has been a tripling of the loss given default incidence for >100K deposits from 15% to 45%. But the same increase is of
course present for <100K deposits, which, since they are legally protected, then require proportionally
larger government rescues. Because of these 'loss condensation policies', in the four large banks in Greece alone, the
Greek government sunk 25 billion Euros essentially to protect deposits. That bill might have been halved if
foreign investors would not have been bailed out by the ECB. In particular French
banking system insider Jean-Claude Trichet helped foreign investors to exit Greek banks and even bought Greek
government bonds at 80 cents/EUR from them. Conclusion: in the presence of an ECB that
copies foreign investor bailouts performed by the IMF in emerging
markets under the 'lender of last resort' disguise and hence increases loss given default incidence for deposits, the proposal for a European deposit
insurance scheme based on mutualizing private bank deposit losses is dead on arrival.

March 2016: Der Spiegel for once got it right here by pointing out the economic benefits of bail-in for Cyprus. Bail-in even of senior unsecured credit helped to save government from bankruptcy and thus protect the economy from a huge demand shock, as in Greece. The implementation by Cyprus and in particular the ECB (where questions of conflict of interest of individual staff when preparing the bail-in legislation have been raised) was counter productive, indicative of the dire lack of co-ordination of bank resolution policies which we hope to solve with the European Single Resolution Board (SRB). However, with growth kicking in, the Cypriot government will perhaps have a window of opportunity - following the solution found in Spain - to correct some of the social imbalances created by the distorted bail-in through transfers to investors. PS - if Mr. Pissarides believes that he wouldn't be bailed in as a senior unsecured creditor in a British bank resolution, he should have a word with the Bank of England.

November 2015: Presentation held at the 3rd International Housing Finance Conference in Seoul/Korea on European mortgage consumer protection. I was asked to do a section on mortgage debt restructuring. In terms of principal reduction, the recent Hungarian case, which now Poland, Croatia and Cyprus try to mimick, excels. I am preparing a paper on the subject to be finished ca April 2016.

June 2015: Comment on the wisdom of taking the Greek banks and their mostly small depositors as hostages in the escalating fiscal dispute between Berlin, Madrid (mind the Spanish elections in late 2015) and Athens (German). With a little bit of game theory you soon understand that rising ECB lending to Greek banks that result from the politically caused bank run is undermining, rather than helping, fiscal hardliners positions. In February or March 2015 it would have been still easy to stop the Greek bank run with open mouth policies. Clear political statements would have confirmed the obvious, namely that Europe since late 2014 with the start of the SSM, the proposal for the SRM and the formulation of the Bank Resolution and Recovery Directive BRRD has a more or less complete, while still implicit, system of deposit insurance. This implies that those very Greek deposits under EUR 100K are protected, just as next door in Bulgaria and Cyprus they were in previous crises, when the banks failed and governments were unable to protect depositors and the Eurozone or the European Union helped out. The Bulgaria case shows that the protection promise holds even in the Grexit case. Moreover, unlike in Cyprus, there are no bail-inable funds left in Greek banks to pay back the ECB. So it is better in the self interest of fiscal hardliners to stop the Greek bank run, reduce their potential exposure from bank deposit rescue operations, thus improve their negotiation position and focus on the fiscal policy items on the agenda.

May 2015: Comment on the potential destabilizing impact that a deepening Bund rout could have on German banks (German). Due to regulatory failure, in particular German regional banks hardly use long-term swaps or bonds to match fund their mortgage portfolios, and in addition hold high levels of long-term bonds. Mortgage originations in the German market due to the dual impact of 'interest binding shopping' by consumers, which has extended the non-callable periods all the way to 15 years on average by May 2015, and the declining rate levels bound for such long periods, show strongly increasing durations. As old 10 year binding periods expire and new non-callable periods get longer, the overall portfolio swiftly gains in duration. Ballooning durations of loans at low interest rates for a long time helped to explain why German house prices were rising while the outstanding mortgage debt level was hardly moving. Just consider that a 2% amortizing 15 year fixed rate bond has a McCauley duration of 12%, i.e. a 1% rate increase would wipe out 4 times the capital that a bank has to hold for that mortgage. Unless .. it is match-funded.

In April 2015 I completed and presented in Brussels a study for DG Competition of the EU Commission on Obstacles to Bail-in of Junior Bank Debt Instruments. In the work program I reviewed obstacles intrinsic to both legacy and new style junior bank debt instruments (esp. AT1), as well as related to incompleteness or inaccuracy of the European Resolution & Recovery 'handbook' under development (Good Bank/dead bank; bad bank/asset swap; mandatory liability management). You surely followed some problem cases, like Hypo Alpe Adria/HETA or Bank of Cyprus/Laiki. This work is unpublished for contractual reasons, I may publish an article or summary going forward.

2014/15 I did intensive consulting work on creating a multi-seller covered bond facility and reformulating the covered bond law in Armenia, financed by the German finance ministry BMF and managed by KfW. Building new financial structure is just as important as tearing obsolete one down, even if you are more of a Mephistopheles character.

October 2014: comment on the severe open banking union problems remaining with the introduction of the SSM in November 2014. These are in particular: an insufficient specification of the early intervention capacity of the SRM, which like FDIC in the US appears as the only guardian of depositor interests in the system against inflated central bank lending and insider creditor rotation; a politics-driven configuration of the banking fee system; and the far too high minimum deposit insurance protection level of EUR 100K which is inconsistent with the fact that the SRM will not enjoy a full faith and credit fiscal backup (just like the FDIC is technically not backed up by the FFC of the United States, whatever the FDIC website says). Kommentar auf Deutsch.

September 2014: interest rate comment (Deutsch) for Hypoport AG. Hypoport, the Berlin SDAX firm where I have my office, is dominating corporate housing finance brokerage in Germany and the largest B2B broker (fee originators 2 banks/insurers) for retail housing finance in Europe.

Can only publish this now. Through May/June 2014 I dug into Depfa Bank plc's historic fate from German taxpayer perspective (Deutsch) for a private sector client, after the German MoF finally decided to wind the bank down rather than selling it. It turns out that in October 2011 Germany wasted another EUR 2 billion by not restructuring / resolving the bank and haircutting hybrids and subordinated debt in the process under the new Irish Special Resolution Regime. This innovative resolution regime had been spearheaded aptly by an Irish government frustrated by high bailout cost. The German finance minister apparently was not frustrated then as much, and simply applied the same bad bank bailouts agreed on for the Landesbanken (left/right pocked for public investors) under Para 6 Finanzmarkt- stabilisierungsfondsgesetz to federal bad banks exchanging assets with private banks under Para 8 of the same law. The Commission almost went mad over the deal, but here in Germany very few seem to care.

NBP workshop Recent
trends in the real estate market and its analysis, 2013 Papers
submitted for publication are now published in the Narodowy Bank Polski
Working Paper Series and will be indexed on IDEAS REPEC and SSRN.August 2014 Contribution of a chapter to The Global Financial Crisis and Housing on Transatlantic Mortgage Boom and Bust. The book has been carefully edited by Susan Wachter, Man Cho and Moon Joong Tcha. Korean Development Institution Series in Policy and Development, Edward Elgar.July 2014 Short comment (in German) on the decision to make ESM funds retroactively available for bank recapitalization in 'individual cases'. Clearly, the motive is to make room for compensatatory interventions, e.g. benefiting Ireland for the rude disruption of the country's sovereignty in October 2010, when a coalition of politicians from countries with large investors in Anglo Irish Bank senior unsecured debt forced the Irish sovereign to absorb their losses. Is there no better way to solve this de-facto bilateral issue than to change the rules of the ESM and open the ESM up for abuses in other cases? See also the 8 banks 8 countries bank restructuring study covering Anglo Irish Bank. Compare the armtwisting of Ireland with the complete neglect of the Danish decision, also in October 2010, to bail in senior unsecured investors in the case of Amagerbanken.

July 2014 Publication of a Finpolconsult study on mortgage prepayment indemnities in Europe (Vorfaelligkeitsentschaedigungen in Europa) as a follow-up on the implementation challenges of the EU CARRP Directive. The study has a broader discussion of the mortgage product menu and its stability implications as well as German mortgage market issues (in German, Anschreiben). German speakers might be interested in the survey on prepayment indemnities in Germany undertaken by the vzbv consumer group, of course always bearing in mind that it is a lobby group pushing its case (just like the banks). Die Welt has press coverage of my study and a piece produced by IW on the subject. For english studies and material on the subject and European mortgage finance in general see the housing finance page on this website.

I get lots of media requests on performance and restructuring issues of Austrian banks, in particular Hypo Alpe Adria (where the Austrian government found a legal lever to void the Carinthian state guarantees for subordinated debt issued by the bank) and the large Austrian banks Erste Bank and Raiffeisen with their significant CEE exposure. See also my work for EBRD on the CEE mortgage sector, which has been a major generator of problems for Western banks. In an economically and politically fragmented region we need more concertation of investment and lending strategies between public and private banks.

March/April 2014: presentations on creditor participation in European bank restructuring at Bruegel Institute (Finance Breakfast), upon invitation of Nicolas Veron, and CDU Wirtschafsrat, Bundesfachkommission Banken. PPTs as per below entries.

March 2014: publication of a study on Central/Eastern European mortgage and covered bond markets (Realkredit- und Pfandbriefmaerkte in Mittel- und Osteuropa) financed in 2012 by a German covered bond software provider (German). The study benefited from the earlier EBRD study available for download below. Covers also commercial real estate markets and additional countries.

January 2014: Presentation given at DG Competition of the European Commission on creditor participation in European bank restructurings. Slight changes vs. the IFO (and December 2013 Cyprus Price Waterhouse conference) versions, e.g. additional material on Slovenia. Presenting at DG COMP on this subject means of course carrying owls to Athens, so I probably learned more from them than they from me.

December 2013: interview with Gold Magazine on the background of the Cyprus creditor bail-in decisions taken in March 2013. I spent a couple of days on the island and came to conclude that the shortcuts taken in March during the purchase and assumption operations (transfer of Greek operations of Laiki and Bank of Cyprus to Piraeus Bank, transfer of Laiki good assets to Bank of Cyprus) and regarding the transfer of legacy ECB debt ('dark matter', which ominously made it from Laiki in Greece to Bank of Cyprus in Cyprus) have produced serious distortions of the outcomes for bank creditors.

I can only hope that with the de-facto establishment of a European FDIC in the form of the SRM, a move that I asked for in the studies of spring and summer below, this degree of operational deficits will become a thing of the past.

October 2013: Study launch "Eight Case Studies on Current Bank Restructurings in Europe", a companion piece to the July 2013 financed by the Center for Financial Studies at the University of Frankfurt (Prof. Jan-Pieter Krahnen). The study widens the country angle from 3 (Greece, Spain, Cyprus) to 8 (in addition Germany, France, Denmark, Netherlands, Ireland) and looks into some of the spectacular cases of this crisis, e.g. Anglo Irish and Dexia. For those of you who are curious why your local bank bailout has become so expensive, learn about at the strangely protective behavior of our governments to even junior bond investors in so many cases and ask yourself how serious Europe will really be in changing her deep bailout policies.

Our press release highlights that it is essentially the small jurisdictions, first and foremost the Netherlands and Denmark, who have adopted clear strategies to increase creditor participation. Ireland was kept from acting. In European bank restructuring policy, small is truly beautiful. I see good reason to demand that European bank supervision and resolution authorities should be headed by representatives from smaller countries, those that have proven that they can do it and are committed to do it.

August 2013: Comment in Handelsblatt on the lack of creditor participation in the Greek bank restructuring program, which has driven up fiscal cost for Greece and increased the risk of future additional sovereign bond haircuts (Deutsch). Back on the envelope I estimate that holders of junior bonds in the four big Greek banks (all distributed via the Channel Islands) will be handed out cash at the tune of EUR 2 billion from the Greek sovereign. Note that once the government is invested in shares with large amounts, as in the Greek case, junior bond holders may lean back and wait for par cash payment. And in the case of dated subordinated securities they will receive coupon payments on top.

Addendum to the July 2013 study publication: In February and March 2013 I was retained by a political party in Bundestag to assess various Cyprus bank restructuring options. A paper was finished in April, available in German language here. It is a precursor exercise to the June/July study covering also Greece and Spain.

July 2013: Study on Creditor Participation in Eurozone Bank Restructurings. This effort has been sponsored by the Green Party in Bundestag and European Parliament. A companion piece is financed by the Center of Financial Studies in Frankfurt and will appear shortly. Neither myself nor certainly the CFS have political party affiliations. But it is good to see that there is interest in such exercises in our parliaments, which have to vote on multi-billion Euro support programs. Yet, high political barriers towards transparency in Europe over banking program cost and their incidence still have to be overcome. So this can only be the starting point of more in-depth empirical reviews.

Here is also a presentation that I gave at the Peterson Institute and the IMF's Crisis Management Department on the empirical substance of the bank restructuring study in early June. We had a good time esp over at the IMF, where denial over the excessive cost of the Greek banking program sat deep with top management.